Botswana Income Tax Act: New Offshore Income Attribution Rule

On 1 July 2026, a provision quietly embedded in Botswana’s rewritten Income Tax Act began reshaping the way the country taxes its residents’ offshore interests. Section 119 introduces what tax professionals call a controlled foreign entity rule – a mechanism that drags qualifying investment income earned by low-tax foreign entities back onto the Botswana tax returns of residents who control them. It is, by any measure, one of the most consequential anti-avoidance provisions Botswana has... The post Offshore Income, Onshore Tax: Botswana’s new attribution rule redraws the boundaries of residency appeared first on Weekend Post.